Privacy Policy

 

Our Commitment

Ethos Pharmaceutical Ethics and Compliance Limited (“Ethos”, “we”, “our”, “us”) is committed to protecting your personal information in accordance with applicable data protection legislation. We strive to maintain your trust and confidence by handling your personal information with respect and transparency. This privacy policy describes how we treat personal information we collect both online and offline. This privacy policy does not apply to individuals employed or engaged by Ethos, or who make an application to work with us as an employee, consultant or other worker.

 

Who we are

For the purposes of the Data Protection Act 2018, the data controller is Ethos Pharmaceutical Ethics and Compliance Limited, a private limited company registered in England and Wales under company number 11368668 with its registered office at St James’s House, 8 Overcliffe, Gravesend, Kent, DA11 0HJ, United Kingdom and trading address at 128 City Road, London, EC1V 2NX, United Kingdom. This means that we are responsible for deciding how we hold, use and keep your personal data secure. It also means we are responsible for responding to requests you make in relation to how your personal data is used by us.

Ethos is registered with the Information Commissioner’s Office (“ICO“) as a data controller under reference ZB038706.

 

How your personal data is collected

We collect your personal data from the following sources:

Directly from you, typically when you:

  • contact us by phone, email, post or communicate with us directly via another channel (such as social media)
  • use our online payment portals
  • complete forms in relation to attending or participating in online or in-person events such as meetings, conferences, workshops, symposia and webinars hosted by us (“Event”), including registering for tickets online (for example when you sign up to attend a symposium)
  • attend and/or participate in an Event
  • interact with a member of our personnel during an Event (for example when you sign up to a mailing list)
  • complete our feedback forms and surveys

Our website, when you:

  • visit and interact with our website
  • register for an Event
  • sign up to a mailing list
  • fill in the online contact form on our website

Our Onyx platform, typically when you:

  • register an Onyx account with us
  • visit and interact with the Onyx platform

Through your employer (or the entity which engages you), when:

  • they wish to register you to use our Onyx platform
  • they wish to contact us with regard to your use of our Onyx platform

 

What personal data do we collect?

We collect the following types of personal data:

  • Identity Data: includes first name, surname, employer and job title
  • Contact details: includes email address, telephone number, home address, billing address
  • Onyx User Data: includes details of your course progress on the Onyx platform, last login, how many times you have signed in, webinar attendance
  • Event Data: includes details of Events that you have attended in the past or for which you are registered to attend in the future
  • Transaction Data: includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data: includes data about your computer, including (where available) your IP address, operating system and browser and device type for system administration. We also collect information regarding the web pages you have viewed, domain type and the URL you came from.
  • Usage Data: includes information about how you use our website and services.
  • Financial Data: we may collect your payment card data over the phone when processing a payment from you, for example when purchasing a subscription for the Onyx platform or paying to attend an event hosted by Ethos. Alternatively, it may also be collected by our third-party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions.
  • Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communications preferences.

We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

How do we use your information?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to process your data where it is necessary for the performance of a contract with you, or to take steps at your request before entering into such a contract;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us; or
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new customer, or a new user on the Onyx platform

 

(a) Identity

(b) Contact

(a) Performance of a contract with you

 

(b) Necessary for our legitimate interests (to perform a contract with your employer)

 

To administer your Onyx account

(a)     Identity

(b)    Contact

(c)     Usage

(d)    Financial

(e)    Onyx User Data

(a) Performance of a contract with you

 

(b) Necessary for our legitimate interests (to perform a contract with your employer/to study how users use our platform/to assist with queries or other communications made through the platform)

 

To perform our contract with your employer, for example, by informing them of your progress on the Onyx platform

 

(a)     Identity

(b)    Onyx User

(c)     Usage

(d)    Technical

Necessary for our legitimate interests (to perform a contract with your employer)

 

To process your order including:

(a) managing payments, fees and charges

(b) collecting and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which could include:

(a) notifying you about changes to our terms or privacy policy

(b) asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to provide feedback about our services or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that we provide or Events that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

Disclosures of your personal data?

We may disclose your personal information to our service providers who operate elements of our services and process data on our behalf. Where such disclosures are made, this will be carried out in accordance with the requirements of relevant data protection laws.

We may share your personal data with the parties set out below for the purposes set out in the table above:

  • Other service providers: such as IT suppliers who host or support our website, our learning management system (LMS, provided by LearnUpon), Eventbrite who provide an event management and ticketing website to register attendees for events, MailChimp who provide an email marketing platform to send newsletters and automated emails, or other service providers who help us analyse the data we hold, send communications to our customers, provide us with legal advice and help us deliver our services to you.
  • Payment processors: Your personal information and payment card details will be processed by Squareup International Ltd (“Square”) or Eventbrite for the purposes of dealing with payment transactions. Your personal information will be processed on our behalf by Square or Eventbrite and your credit/debit card details are shared with Square or Eventbrite. We will ensure that your personal information will be adequately protected as required by data protection law.
  • Professional advisers: who provide consultancy, banking, legal, insurance and accounting services.
  • Police and law enforcement: to assist with the investigation and prevention of crime, and where we are required to do so by law or to assist with their investigations or initiatives. This includes the ICO.
  • Regulatory authorities: HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

For further details, see https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-transfers-a-guide/.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

How long do we keep your information for?

Your personal data shall be kept for no longer than is reasonably necessary for the purposes set out above, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

This period will vary depending on your interactions with us. For example, where you have subscribed to the Onyx platform we will keep a record of your personal data until your subscription ends, after which your Onyx account will be disabled and you will be given the opportunity to renew your subscription or close your account. If you choose to close your account, we will delete your account within 1 month of receiving your account closure request. We may keep records of other data such as your course progression for a longer period.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

How can I opt out from receiving marketing?

If you tell us that you are interested in receiving marketing communications from us, or sign up to our newsletter or ask us to send it to you, we may keep you informed by email about this and other products or services that we think may be of interest to you.

You have the right to ask us not to process your personal information for marketing purposes, or to change your mind at any time. You can opt out by:

  • Unsubscribing from our newsletters by following the link on the bottom of the newsletter; or
  • Emailing: enquiry@pharmaethos.com

 

Your data privacy rights

Under certain circumstances, you have rights under data protection laws in relation to the personal information we hold about you.

  • Right of access

You have the right to request access to the personal data that Ethos holds about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Right to rectification

The accuracy of your information is important to us. If the personal information we hold about you is inaccurate or incomplete, you are entitled to request that we rectify it. If you change email address, or any of the other information we hold is inaccurate or out of date please email us at: enquiry@pharmaethos.com

  • Right to erasure

You have the right to request erasure of your personal data held by us where there is no good reason for us to continue processing it. This includes where our purposes for processing your personal data have come to an end, where our processing was based on your consent which you have withdrawn, where you object to our processing of your personal data based on legitimate interests and we have no overriding legitimate grounds to continue to process your personal data, or if we have processed it unlawfully.

  • Right to restrict processing

You have the right to ask us to restrict processing of your personal data if you contest the accuracy of your personal information and we need to verify its accuracy, if we have unlawfully processed your information and you do not want us to erase the data, if we no longer need your information but you need us to keep it in order to establish, exercise or defend a legal claim, you have objected to us processing your information or we are considering whether we have legitimate grounds to continue to process it. As a matter of good practice, we may automatically restrict processing of your personal information while we consider its accuracy or the legitimacy of processing it.

  • Right to object

You can ask us to stop processing your personal information where we are relying on our legitimate interests to justify the processing and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You can also object to us using your information for direct marketing purposes.

  • Right of data portability

You have the right to request that we transfer to you a copy of your data in a commonly used machine-readable format or to ask us to transfer this to a third party of your choice. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Right to lodge a complaint with the supervisory authority

If you are unhappy about the way we have handled your data and we have been unable to resolve your complaint, you can report it to the ICO. You can find details about how to do this on the ICO website: https://ico.org.uk/concerns/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  • Right to withdraw consent

Where we are relying on your consent to process your personal data, you can notify us that you have withdrawn your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

How to contact us

If you need to contact us to discuss any aspect of this policy you may do so by emailing enquiry@pharmaethos.com

 

Updates to our Privacy Policy

This Privacy Policy will be amended if we make any changes to the way we collect, store and use personal data. We recommend that you check for updates to this Privacy Policy from time to time. We will notify you directly about changes to the way we use your personal data when we are legally required to do so.

This privacy policy was last updated in October 2023.